What is the test for a police officer's statement that a suspect has been detained during a patdown search?

23. In Holloway, police officers were on foot patrol at 2:58 a.m. in a residential area of Pasadena where narcotics traffic regularly occurred. They observed a defendant and four other men on a grassy area next to a large apartment complex. The defendant frequented the area but did not reside there. Because the officers approached the five men from behind, none saw the officers until they were almost upon the group. One of the four men with the defendant then saw the officers and said something. The group fled, except the defendant, who remained unaware of the officers' presence. An officer who approached the defendant was three feet from him when the defendant realized the officer was there. The defendant manifested surprise, and the officer stated, "'Hold it.'" (People v. Holloway, supra, 176 Cal.App.3d at pp. 152-153.) In Holloway, Division Two of this court suggested that the officer's statement was not a detention but concluded that, even if it was a detention, it was lawful. (Id. at pp. 153-155.) We note that, before appellant put his hands up, there was no seizure. (People v. Arangure, supra, 230 Cal.App.3d at p. 1307.)

23. In Holloway, police officers were on foot patrol at 2:58 a.m. in a residential area of Pasadena where narcotics traffic regularly occurred. They observed a defendant and four other men on a grassy area next to a large apartment complex. The defendant frequented the area but did not reside there. Because the officers approached the five men from behind, none saw the officers until they were almost upon the group. One of the four men with the defendant then saw the officers and said something. The group fled, except the defendant, who remained unaware of the officers' presence. An officer who approached the defendant was three feet from him when the defendant realized the officer was there. The defendant manifested surprise, and the officer stated, "'Hold it.'" (People v. Holloway, supra, 176 Cal.App.3d at pp. 152-153.) In Holloway, Division Two of this court suggested that the officer's statement was not a detention but concluded that, even if it was a detention, it was lawful. (Id. at pp. 153-155.) We note that, before appellant put his hands up, there was no seizure. (People v. Arangure, supra, 230 Cal.App.3d at p. 1307.)

24. Appellant's detention during his patdown search was also proper since, on this record, Huber had reasonable grounds to believe that appellant was armed and dangerous. (Cf. People v. Limon (1993) 17 Cal.App.4th 524, 534 [standard for validity of patdown search].) For all the record reflects, when Huber observed the second male run, Huber reasonably could have suspected that the second male fled because appellant had committed an armed crime against the second male.

24. Appellant's detention during his patdown search was also proper since, on this record, Huber had reasonable grounds to believe that appellant was armed and dangerous. (Cf. People v. Limon (1993) 17 Cal.App.4th 524, 534 [standard for validity of patdown search].) For all the record reflects, when Huber observed the second male run, Huber reasonably could have suspected that the second male fled because appellant had committed an armed crime against the second male.